JAMIE LAIQUAN FRAZIER
v.
STATE OF FLORIDA

Fla. 1st DCA | 2025-12-03
No. 2024-2329
Clark, J., Bilbrey, J., Kelsey, J., Long, J.
2025 FL 11340 Florida District Court of Appeal, First District (2025)

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Holding

The use of information from a person not recorded or listed as a confidential informant by law enforcement does not violate section 914.28, Florida Statutes, and even if it did, the statute provides that any failure to comply may not be relied upon to create enforceable rights in a criminal proceeding.


Headnotes

[1] A failure to comply with Florida Statutes section 914.28 regarding confidential informant procedures does not create any substantive or procedural right enforceable by a…

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Key Quotes

“any failure to abide by this section may not be relied upon to create any additional right, substantive or procedural, enforceable at law by a defendant in a criminal proceeding.”

Section 914.28(8), Florida Statutes, regarding confidential informant procedures

Facts & Procedural History

Frazier was convicted by jury of trafficking in fentanyl. Law enforcement officers obtained initial information from a person who was not recorded or …

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Per_curiam
Per Curiam

FIRST DISTRICT COURT OF APPEAL

STATE OF FLORIDA

_____________________________

No. 1D2024-2329 _____________________________

JAMIE LAIQUAN FRAZIER,

Appellant,

v.

STATE OF FLORIDA,

Appellee. _____________________________

On appeal from the Circuit Court for Bay County. Brantley S. Clark, Jr., Judge.

December 3, 2025

PER CURIAM.

In this Anders∗ appeal, Appellant challenges his judgment and sentence, entered after the jury found him guilty of trafficking in fentanyl, because law enforcement officers initially used information relayed to them by a person not recorded or listed by the Bay County Sheriff’s Office as a confidential informant. The evidence at trial showed that the person was not a “confidential informant” as defined by section 914.28(2)(b), Florida Statutes (2023). And even if the statute applied, section 914.28(8) provides, “any failure to abide by this section may not be relied upon to

∗ Anders v. California, 386 U.S. 738 (1967).

2 create any additional right, substantive or procedural, enforceable at law by a defendant in a criminal proceeding.” Because our independent review of the record did not reveal any properly preserved meritorious point which might support reversal of the judgment or sentence, and no fundamental error occurred, the judgment and sentence are affirmed. See Neal v. State, 142 So. 3d 883, 887 (Fla. 1st DCA 2014); § 924.051(3), Fla. Stat. BILBREY, KELSEY, and LONG, JJ., concur.

_____________________________

Not final until disposition of any timely and authorized motion under Fla. R. App. P. 9.330 or 9.331. _____________________________

Jessica J. Yeary, Public Defender, and Kasey Lacey, Assistant Public Defender, Tallahassee, for Appellant; Jamie Laiquan Frazier, pro se, Appellant.

James Uthmeier, Attorney General, Tallahassee, for Appellee.


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